Tax Justice Network ¦ Integrating the Collection, Use and Exchange of Real Estate Ownership Information

Why real estate transparency matters

Real estate is one of the most attractive assets for criminals, corrupt actors, sanctioned persons, and tax evaders. It is valuable, durable, and often easy to hold through layers of companies, trusts, nominees, and other legal arrangements. That is why transparency in real estate ownership is not just a property-law issue.

Looking only at the legal owner of a property is often not enough. Authorities also need to know who benefits from the property, who controls it, who finances it, who lives in it, and what other rights exist over it. Without that fuller picture, hidden ownership structures can mask money laundering, corruption, sanctions evasion, and tax evasion.

Legal title is only part of the story

A person may appear in the land registry as the owner, yet someone else may actually enjoy the property or control it. The Tax Justice Network report provides useful examples. A house may be held by one person as bare owner, while another person holds a usufruct right and someone else lives there under a lease. A mortgage may also reveal a financier who has a legal interest in the property. If investigators only look at title, they may miss the people actually linked to the asset.

This becomes even more complicated when trusts or private foundations are used. In such structures, the person listed as owner may be only a nominee or trustee, while the real economic control sits elsewhere. In some jurisdictions, the trustee appears in the registry as if they were the full owner, which can create serious confusion unless their trustee status is clearly recorded.

Bastian Schwind-Wagner _Follow

"Real estate transparency is a critical tool for fighting money laundering, corruption, sanctions evasion, and tax evasion. The report shows that legal title alone often hides the real people who own, control, benefit from, or use property.

A stronger system would connect land registries, tax data, beneficial ownership records, and other relevant sources. That would give authorities faster, more complete access to the information they need to detect hidden property structures and investigate financial crime."

Different sources hold different pieces of the puzzle

The report shows that information about real estate is fragmented across many sources. No single database usually contains the full picture.

The land registry is the most important source for local property. It often contains the legal owner, the property address, and registered rights such as mortgages or usufruct. Its strength is that it is usually official, accurate, and low risk from a tipping-off perspective. Its weakness is that it usually records legal ownership only, not beneficial ownership.

Tax authorities can hold valuable real estate data too, especially where wealth taxes, capital gains taxes, inheritance taxes, or rental income reporting apply. Tax records may reveal both local and foreign property interests, depending on the tax system. But the data is usually shaped by tax rules, thresholds, and compliance incentives, so it is rarely complete. Fiscal secrecy also limits access by other authorities.

Financial intelligence units can receive very useful information through suspicious transaction reports (STRs). This may include beneficial ownership, source of funds, and transaction details. But FIU data is reactive and incomplete by nature. It depends on what obliged entities report, so it cannot serve as a national property map.

Banks, insurers, real estate brokers, and public notaries can also collect helpful information. They may know the property value, the buyer, the legal owner, the beneficial owner, and the financing structure. Public notaries are especially important in Civil Law countries, where notarial involvement is often required for property transfers. Still, their records are decentralized, and authorities may need to know exactly which professional handled the transaction before they can obtain the data.

Private companies such as utility providers, delivery services, and digital platforms can help identify who actually occupies or uses a property. That information can be useful in investigations, but these companies do not usually record ownership or full legal rights.

Why beneficial ownership is essential

A central argument in the report is that beneficial ownership information is key to effective transparency. Criminals rarely hold valuable property in their own names if they can avoid it. They often use companies, trusts, or other legal vehicles to separate title from control and benefit.

That means authorities need to know not only who owns the property legally, but also who ultimately stands behind the entity that owns it. This is especially important when property is held through offshore structures or when foreign entities hold local real estate. In many countries, beneficial ownership registration does not fully cover foreign legal persons or trusts that own property. That creates a major gap and an incentive for secrecy.

Cross-border real estate creates bigger blind spots

The report also stresses that transparency becomes much harder when property is abroad. A local taxpayer may own real estate in another country, or a foreign entity may own local property. In those cases, domestic systems are often not enough.

Mutual legal assistance (MLA) can help in criminal cases, but it is slow and formal. FIU-to-FIU exchanges can be quicker, but the information exchanged is intelligence rather than evidence. Tax cooperation is the most developed cross-border route, especially through automatic exchange frameworks, but the main limitation is that information is generally usable only for tax purposes unless domestic law allows broader sharing.

The main automatic exchange tools

The report highlights four OECD frameworks that can directly or indirectly reveal real estate-related information.

The first is the automatic exchange of immovable property information, or IPI. This is the closest thing to a global automatic exchange framework for real estate. It can cover legal owners, beneficial owners, property identifiers, property value, and disposal or rental-related income. But it has a major limitation: it only exchanges information that is already “readily available” in domestic systems. It does not force countries to collect more data.

The second is the Digital Platform Information framework, or DPI. This can capture rental income where properties are listed on platforms. It may reveal the property address, rental totals, and fees. It is useful for tax authorities, but it still does not directly solve ownership transparency.

The third is the Common Reporting Standard, or CRS. It can show financial accounts connected to rental income or property proceeds, but it rarely reveals real estate directly.

The fourth is the Crypto-Asset Reporting Framework, or CARF. It may indirectly help where property transactions or rental payments are made in crypto, but again it is only an indirect clue.

What an ideal system would look like

The report proposes an ideal transparency model in which real estate information is digitised, systematised, and integrated across official sources. In that model, the real estate registry would become the central platform, but it would not work alone. It would connect with beneficial ownership registries, commercial registries, tax authorities, financial intelligence units (FIUs), public notaries, and even some private-sector data holders where appropriate.

The goal is not to make the land registry collect everything directly from the public. Instead, the goal is to integrate information already held elsewhere so that authorities can see the full ownership chain, the legal and beneficial owners, and other interests in the property.

That model also requires unique identifiers that link different databases together. Without consistent identifiers, information stays trapped in separate systems and cannot be matched effectively.

Practical steps toward better transparency

The report recommends a staged approach. First, countries should strengthen their real estate registries so they cover the whole territory, are centralised, and are digitised. Then they should expand the information recorded to include more than title, such as mortgages, usufruct, leases, and trustee status.

Next, beneficial ownership rules should be widened to cover foreign entities and legal arrangements that hold property. Registries should be interconnected through common identifiers. Authorities should have secure, direct, and in some cases bulk access to the data they need. Where appropriate, the public should also have access to some of this information to support accountability.

The report also supports mandatory discrepancy reporting, so that if a notary, bank, tax authority, or other obliged entity sees something inconsistent, that inconsistency must be reported. In addition, mandatory disclosure rules can force reporting of schemes designed to hide ownership, such as certain trust structures.

Why this matters for financial crime investigations

For investigators, the value of integrated real estate information is clear. It helps identify unexplained wealth, hidden assets, suspicious transfers, tax underreporting, and property used by sanctioned or corrupt actors. It also improves asset tracing and recovery .

A fragmented system leaves investigators chasing partial facts across multiple institutions, often slowly and with legal barriers. An integrated system reduces that friction and makes it harder to hide behind formal ownership alone.

The bigger message

The report’s core lesson is simple: real estate transparency only works when legal ownership, beneficial ownership, financing, use, and cross-border information are viewed together. Property is not just a title in a registry. It is a network of relationships that can be used to hide wealth or expose it.

For financial crime prevention, that full picture is essential.

Dive deeper

• Tax Justice Networl ¦ Integrating the Collection, Use and Exchange of Real Estate Ownership Information ¦ Link